Epstein Secrets

ubmitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 4 The defense attorneys' also propose to file a motion for a protective order if their mot

.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

even applies. In any event, it is obvious that grand jury secrecy only extends to matters that occurred in secret before the grand jury. See, e.g., Blalock. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

spectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys for Jane Doe #1 and Jane Doe #2 8 EFTA00207974 Case 9:08-cv-80736-KAM Document 74 Entered on FLSD

& LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys fo

Statest Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock' United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

TED: May 2. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 II EFTA00208034 Case 9:08-cv-80736-KAM Document 75 Entered on FLSD Docket 05)02 2011 Pa

tates.. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock'. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside t

red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

ates v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside